Services
Three Cord True Wealth Management, LLC (“3CTWM” or “Adviser”) offers asset management
services based on the individual needs of the client. This Brochure provides a description of the
advisory services offered under the 3CTWM II wrap fee program.
For more information about 3CTWM ’s other investment advisory services, please contact
3CTWM for a copy of the Firm’s Form ADV 2A brochure that describes such services or go to
https://adviserinfo.sec.gov. The Firm’s CRD #307480.
3CTWM serves as the sponsor and portfolio manager of the 3CTWM II wrap fee program. Wrap
fee program generally charge clients a specified “bundled” fee (typically a percentage of assets
under management) for discretionary investment management services and trade execution
costs. For clients invested in the 3CTWM II wrap fee program, the Firm provides ongoing
investment advice and management on assets in the client’s account. 3CTWM provides advice
on the purchase and sale of various types of investments, such as mutual funds, exchange-traded
funds (“ETFs”), variable annuity subaccounts, equities, and fixed income securities. 3CTWM
provides advice that is tailored to the individual needs of the client based on the investment
objective chosen by the client. Clients can impose restrictions on investing in certain securities
or groups of securities by indicating in the written advisory agreement with 3CTWM.
3CTWM provides management services on a discretionary basis. The client authorizes the Adviser
to have discretion by signing an advisory agreement.
Assets for program accounts are held at LPL Financial (“LPL”) as custodian. LPL also acts as
executing broker/dealer for transactions placed in program accounts and provides other
administrative services as described throughout this Brochure.
Fees
In the 3CTWM II wrap fee program, clients pay 3CTWM a single annual advisory fee for advisory
services and execution of transactions. Clients do not pay brokerage commissions, markups or
transaction charges for execution of transactions in addition to the 3CTWM advisory fee. The
advisory fee is negotiable between the client and 3CTWM and is set out in the advisory
agreement. The 3CTWM fee is a percentage based on the value of all assets in the account,
including cash holdings. Fees range from .7% to 1.3% annually which can be higher than the fee
charged by other investment advisors for similar services. The advisory fee is paid to 3CTWM.
3CTWM does not accept performance-based fees for program accounts.
The advisory fee is deducted from the account by LPL as the custodian of assets based on a
written authorization from the client. LPL calculates and deducts the advisory fee quarterly in
advance. If the 3CTWM agreement is terminated before the end of the quarterly period, client
is entitled to a pro-rated refund of any pre-paid quarterly advisory fee based on the number of
days remaining in the quarter after the termination date.
Other Types of Fees and Charges
Program accounts will incur additional fees and charges from parties other than 3CTWM as noted
below. These fees and charges are in addition to the advisory fee paid to 3CTWM. 3CTWM does
not share in any portion of these third-party fees.
LPL, as the custodian and broker-dealer providing brokerage and execution services on program
accounts, will impose certain fees and charges. LPL notifies clients of these charges at account
opening and makes available a list of these fees and charges on its website
at www.lpl.com. LPL
will deduct these fees and charges, as applicable, directly from the client’s program account.
These fees may include but are not limited to wire fees, ACH fees, overnight carrier fees, etc.
There are other fees and charges that are imposed by other third parties that apply to
investments in program accounts. Some of these fees and charges are described below.
• If a client’s assets are invested in mutual funds or other pooled investment products, clients
should be aware that there will be two layers of advisory fees and expenses for those assets.
Client will pay an advisory fee to the fund manager and other expenses as a shareholder of
the fund. Client will also pay 3CTWM the advisory fee with respect to those assets. Most of
the mutual funds available in the program are purchased directly. Therefore, clients could
generally avoid the second layer of fees by not using the management services of 3CTWM
and by making their own investment decisions.
• Certain mutual funds impose fees and charges such as contingent deferred sales charges,
early redemption fees and charges for frequent trading. These charges apply if client assets
transfer into or purchases such a fund with the applicable charges in a program account.
• Although only no-load and load-waived mutual funds can be purchased in a program account,
client should understand that some mutual funds pay asset-based sales charges or service
fees (e.g., 12b-1 fees) to the custodian with respect to account holdings.
• If client holds a variable annuity as part of an account, there are mortality, expense and
administrative charges, fees for additional riders on the contract and charges for excessive
transfers within a calendar year imposed by the variable annuity sponsor.
Further information regarding fees assessed by a mutual fund, or variable annuity is available in
the appropriate prospectus, which is available upon request from the Adviser or from the product
sponsor directly.
Other Important Considerations
Although clients do not pay a transaction charge for transactions in a wrap fee account, clients
should be aware that
3CTWM pays LPL transaction charges for those transactions. The
transaction charges paid by 3CTWM vary based on the type of transaction (e.g., mutual fund,
equity or ETF) and for mutual funds based on whether or not the mutual fund pays 12b-1 fees
and/or recordkeeping fees to LPL. Transaction charges paid by the Adviser for equities and ETFs
are $9. For mutual funds, the transaction charges range from $0 to $26.50. Because 3CTWM pays
the transaction charges in these accounts, there is a conflict of interest in cases where mutual
funds are offered at both $0 and $26.50. Clients should understand that the cost to the Adviser
of transaction charges is a factor that 3CTWM considers when deciding which securities to select
and how frequently to place transactions in a wrap fee account.
In many instances, LPL makes available mutual funds in a 3CTWM II wrap fee account that offer
various classes of shares, including shares designated as Class A Shares and shares designed for
advisory programs, which can be titled, for example, as “Class I,” “institutional,” “investor,”
“retail,” “service,” “administrative,” “platform” or” Adviser” share class. The Adviser Share Class
offered for a particular mutual fund in many cases will not be the least expensive share class that
the mutual fund makes available and was selected by LPL in certain cases because the share class
pays LPL compensation for the administrative and recordkeeping services LPL provides to the
mutual fund. Additionally, LPL does not aggregate client assets for purposes of qualifying for a
lower expense share class. Clients should understand that another financial services firm can
offer the same mutual fund at a lower overall cost than is available through the wrap fee account.
In other instances, a mutual fund may offer only Class A Shares, but another similar mutual fund
is available that offers a less expensive share class. Class A Shares typically pay LPL a 12b-1 fee
for providing shareholder services, distribution, and marketing expenses (“brokerage-related
services”) to the mutual funds. Adviser Share Class funds generally are not subject to 12b-1 fees.
3CTWM has a financial incentive to recommend share classes that have the lowest trading costs
in cases where various share classes are available. This is a conflict of interest which might incline
3CTWM, consciously or unconsciously, to render advice that is not disinterested. Although the
client will not be charged a transaction charge for transactions, the Adviser pays LPL a per
transaction charge for certain mutual fund trades in your account. 3CTWM does not pay
transaction charges for share classes that “Fully Participate” on the LPL platform, but generally
does pay transaction charges for other share classes that are “Non-Participating”. This creates an
incentive for 3CTWM to select Fully Participating funds. Clients should note that Fully
Participating funds can be more expensive than Non-Participating funds. Furthermore, as noted
above, the share classes available may not be the least expensive share class offered by the fund
company. The cost to 3CTWM of transaction charges is a factor the Adviser considers when
deciding which securities to select and whether or not to place transactions in the account.
The lack of transaction charges to 3CTWM for Fully Participating share class purchases and sales,
together with the fact that other shares have a trading cost, presents a conflict of interest
between 3CTWM and the client. In short, it costs 3CTWM less to recommend and select Fully
Participating mutual funds than Non-Participating funds. Clients should understand this conflict
and consider the additional indirect expenses borne as a result of the mutual fund fees when
negotiating and discussing with your Adviser the advisory fee for management of an account.
The advisory fee is an ongoing wrap fee for investment advisory services, the execution of
transactions and other administrative and custodial services. The advisory fee can cost the client
more than purchasing the program services separately, for example, paying an advisory fee plus
commissions for each transaction in the account. Factors that bear upon the cost of the account
in relation to the cost of the same services purchased separately include the type and size of the
account, historical and or expected size or number of trades for the account, and number and
range of supplementary advisory and client-related services provided to the client.
The advisory fee can cost the client more than if assets were held in a traditional brokerage
account. In a brokerage account, a client is charged a commission for each transaction, and the
representative has no duty to provide ongoing advice with respect to the account. If the client
plans to follow a buy and hold strategy for the account or does not wish to purchase ongoing
investment advice or management services, the client should consider opening a brokerage
account rather than a program account.
The Adviser recommending the program to the client receives compensation because of the
client’s participation in the program. This compensation includes the advisory fee and other
compensation, such as bonuses, awards or other things of value offered by LPL to 3CTWM or its
associated persons. The amount of this compensation can be more or less than what the 3CTWM
would receive if the client participated in other LPL programs, programs of other investment
advisors or paid separately for investment advice, brokerage, and other client services.
Therefore, the 3CTWM has a financial incentive to recommend a program account over other
programs and services.
The investment products available to be purchased in the program can be purchased by clients
outside of a program account, through broker-dealers or other investment firms not affiliated
with 3CTWM.